Insights

Partial Fix to FATCA

The Senate Hearing on unintended consequences of FATCA on April 26th may not have been a lively affair but, as a non-American with some small knowledge of the subject matter, it was certainly very interesting to hear the different viewpoints offered to the committee....

Further Information Reporting for Financial Institutions

2017 is going to be a very interesting year for financial institutions, compliance departments and Responsible Officers with CRS, Automatic Exchange of Information (AEoI), Base Erosion and Profit Shifting (BEPS) and US Section 871(m) all coming into play in some shape...

Publication 5262 – QI Portal

Continuing the burst of activity, what better way to start a new year, than with a new QI, WP & WT portal and its bed time reading material, Publication 5262, which of course goes hand in hand with the new QI Agreement,Revenue Procedure 2017-15.

Impacts of the 2017 Form W-8 BEN

The beginning of 2017 has seen a burst of activity from the IRS. The new QI and FFI agreements are rightly gaining a lot of attention, as the industry adapts to the new challenges faced by the QDD regulations and 871(m). Thus far largely overlooked is the humble Form...

7 Things You Need To Know To About US Tax Regulations In 2017

The transition from 2016 to 2017 has been anything but boring from a tax perspective. The US market in particular has seen several changes to the tax system as it’s viewed by those outside the US. Here are just seven changes that will have an impact on...

Notice 2016-76 – Phased implementation of Section 871(m)

Late on Friday (as far as the UK is concerned) the IRS issued the snappily titled “Notice 2016-76 IRS Enforcement and Administration of Section 871(m) and Related Withholding Provisions During the Phase-In Period” notice. The document lays out how the IRS intends to...